FCB WORLDWIDE INC.

Note: On October 6, 2015, the European Court of Justice issued a judgment declaring the U.S.-EU Safe Harbor framework “invalid.” For past several years, the FCB Safe Harbor Agencies mentioned below have been participants in Safe Harbor for certain transfers of personal information from the European Economic Area (“EEA”) and Switzerland to the U.S. as described in the FCB Safe Harbor Privacy Policy below. The FCB Safe Harbor Agencies will continue to abide by the Safe Harbor privacy principles of Notice, Choice, Onward Transfer, Security, Data Integrity, Access, and Enforcement with respect to the EEA/Swiss personal information that they received while they were participants in the Safe Harbor program.

SAFE HARBOR PRIVACY POLICY

FCB Worldwide Inc. (“FCB”) recognizes that the European Union and Switzerland have implemented “omnibus” data protection regimes established pursuant to the European Data Protection Directive (95/46/EC) and the Swiss Federal Act on Data Protection, respectively (collectively, “Data Protection Law”). Among other obligations, Data Protection Law generally requires “adequate protection” for the transfer of certain individually identifiable data about individuals in the Europe to FCB operations in the United States. FCB Worldwide, Inc.’s agencies of Area 23, Neon, Prohealth, FCB Health and FCB New York (formerly FCB Garfinkel) (collectively, “FCB Safe Harbor Agencies”) accordingly adhere to the requirements of the U.S.-EU and the U.S.–Swiss Safe Harbor Frameworksas set forth by the by the United States Department of Commerce (“Safe Harbor”) with respect to certain EU and Swiss Personal Data received in the United States about its client contacts (“European Client Contact Information”) and consultants and certain other thirds parties it has engaged (“European Consultant Information”) in the EU and Switzerland (collectively, “European Personal Information”) (such individuals, “European Data Subjects”) for the purposes described below.

FCB Safe Harbor Agencies may use European Client Contact Information for the following purposes: providing services for clients; marketing products and services to clients, fulfilling client requests, responding to client inquiries, tracking payment for advertising or marketing support services, creating materials for clients, managing client relationships, general communications, collecting payment for services, and compliance with company policies and applicable law. FCB Safe Harbor Agencies may use European Consultant Information for the following purposes: general communications; managing engagements and relationships, contracting, providing payment for services, and compliance with company policies and applicable law.

FCB Safe Harbor Agencies may disclose European Personal Information to its affiliates, subsidiaries, business partners, and service providers for the purposes listed above. In situations where FCB Safe Harbor Agencies disclose European Personal Information to any recipients acting as service providers or “agents” on behalf of FCB Safe Harbor Agencies, such recipients will be required to protect the disclosed European Personal Information in accordance with the relevant Safe Harbor Principles, or otherwise take steps to ensure that the European Personal Information is appropriately protected.

Data Security, Integrity and Access. FCB Safe Harbor Agencies take reasonable precautions to protect European Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. FCB Safe Harbor Agencies make reasonable efforts to keep European Personal Information reliable for its intended use, accurate, complete and current to the extent necessary for the purposes for which we use the European Personal Information. FCB Safe Harbor Agencies also provide European Data Subjects with a reasonable opportunity to review, correct or delete their own European Personal Information in accordance with Safe Harbor rules. European Data Subjects may contact the FCB Safe Harbor Privacy Contact identified below to review European Personal Information about them. FCB Safe Harbor Agencies reserve the right to take reasonable steps to authenticate the identity of any such individual seeking access to European Personal Information.

Other Disclosures. FCB Safe Harbor Agencies may disclose European Personal Information as necessary in connection with the sale or transfer of all or part of the business, where required or permitted by law, where the FCB Safe Harbor Agencies believe that such disclosures are appropriate in connection with a law enforcement request or otherwise permitted by Safe Harbor, or in order to investigate, prevent or take action regarding illegal activities or suspected fraud or enforce or apply FCB agreements.

Safe Harbor Questions

Any questions regarding this Safe Harbor section of this Privacy Policy or requests for access to European Personal Information should be directed to the Safe Harbor Privacy Contact listed in this section. Additional information, including information on the Safe Harbor certification of the FCB Safe Harbor Agencies, may be obtained on the United States Department of Commerce website at http://www.export.gov/safeharbor In addition, if any individual located in the EU or Switzerland who experiences an issue regarding the European Personal Information that the FCB Safe Harbor Agencies hold about him or her that he or she cannot resolve directly with the FCB agency, the individual may contact the DMA Safe Harbor Dispute Resolution Program per the contact information listed in this section. The DMA will then serve as a liaison to us to resolve your concerns.

This policy may be changed from time to time, consistent with the requirements of Safe Harbor. You can determine when this Policy was last revised by referring to the “Last update” data at the bottom of this page. Any changes to this policy will become effective upon our posting of a revised Policy on the Site.